The following information is contributed by Rick Hartwig and the Environmental, Health, and Safety Affairs Department of Printing Industries of America. Get ready for changes to your Hazard Communication program! After years of effort, theOccupational Safety and Health Administration (OSHA) revised its Hazard Communication Standard (HCS) to align with the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals (GHS). The revision was made to provide for consistency and to allow employees to better understand hazards, which will result in improved compliance, easier program management, and fewer injuries and illnesses.   The changes outlined under the new standard will be phased in over time and will be fully in effect by June 1, 2016. This rule includes three major changes to the current standards: Hazard classification. The definitions of “hazard” have been changed to provide specific criteria for classifications of health and physical hazards, as well as the classification of mixtures. The chemical manufacturer and importer are still responsible for hazard classification. Labels for chemical containers. Chemical manufacturers and importers will be required to provide a label that includes a signal word, pictogram, and hazard statement for each hazard class and category. Precautionary statements must also be provided. Safety data sheets. These documents will eventually replace the Material Safety Data Sheet (MSDS) and will now have a uniform and specified 16-section format. The compliance requirements for the Safety Data Sheet (SDS) will essentially be the same as was required in the current standard. As a result of the changes to labeling and SDS’s, OSHA will require modified employee training to be provided. The revised rule requires that all applicable workers be trained on the new label elements and SDS format by December 1, 2013 in order to be prepared once the new information is released into the market. Also, in the event any new physical or health hazards are identified, additional employee training on the new information must be completed by June 1, 2016. This modified training is in addition to the current standard’s training requirements. The printing industry will primarily be affected by the labeling and Safety Data Sheet changes to the Hazard Communication Standard, as well as the training requirements that accompany these changes. OSHA will require employers who use an in-plant labeling system to update their labeling program, so companies should begin evaluating the labeling system used for in-plant containers during the transition period. Although the changes do not directly affect the written program requirements of Hazard Communication Standard, OSHA will require employers to update, as necessary, any portion of their programs that would reflect changes such as terminology, definitions, training, or any change in policies as a result of the new revision. To...

Over the last year or so, OSHA has been under scrutiny from the Department of Labor for not taking enough measures with to enforce current standards and rules, especially toward companies that demonstrate an indifference to meeting compliance. As a result OSHA has implemented several enforcement initiatives that are greatly impacting vast numbers of printers today. One of the initiatives involves National Emphasis Programs (NEP). These are inspection programs designed to target specific industries and hazards. Applicable to the printing industry are the Amputation NEP, Combustible Dust NEP, and the Injury and Illness RecordkeepingNEP.Under each of these NEPs printing operations and printing equipment have been specifically identified and require OSHA to seek printers in their area for inspections.   Once an inspection occurs, OSHA will attempt to determine whether or not there are violations and whether or not a company is considered a “severe violator,” which is another enforcement initiative. OSHA’s Severe Violator Enforcement Program (SVEP) is applied when a company demonstrates an “indifference” to meeting OSHA compliance. Under the SVEP program, OSHA can issue willful, repeat, and/or failure-to-abate citations with much higher penalties and enhanced settlement requirements.  The issue of higher penalties brings us to the more recent policy change regarding OSHA’s penalty classification. Because of the many violations noted by OSHA inspectors, OSHA believes the penalties are too low to have an adequate deterrent effect. Based on inspection data, OSHA has increased the number of years it will look back for previous violations, which will increase the number of potential repeat violations. OSHA has also limited the initial penalty reduction allowance from 50% to 30% which has increased the average penalty for serious citations to a base of $3,000–$4,000 for each citation. First and foremost, with all OSHA inspections, being prepared ahead of time is the key to avoiding citations and penalties. Second, cooperation with the inspector is important, but be careful of what information is provided when asked. Always record what occurs during the inspection process and ask the inspector to clarify or explain the actual OSHA standard for any issues raised. OSHA inspections will usually take multiple days with multiple inspectors to cover the applicable programs. Being proactive is the best defense. If you need help in this area, please contact me at rhartwig@printing.org or 412-259-1792.  There is also a free publication available to members, OSHA Primer, which will provide a basic overview of the federal OSHA regulations affecting printers. This publication, as well as other compliance tools, is available at www.printing.org/osha....

The 2011 Continuous Improvement Conference recently came to a close (we’ll have a wrap-up of the conference coming soon!), and if you weren’t able to attend, don’t worry, we have you covered. We recorded a series of videos focusing on the fundamentals of continuous improvement and operational excellence. Embedded below, you’ll find videos that answer some of the basic questions like: How to budget for Lean transformation, why Lean, and what metrics need to be measured. Let us know what you think of the videos in the comments below.        ...

The 2011 Continuous Improvement Conference is happening right now in Kansas City, Missouri and if you couldn’t make it there year, fear not, there’s still learning to be had. We have a series of videos entitled “Ask Ken: Operational Excellence for Printers” that answer some of the fundamental questions about lean and operational excellence such as why use Lean and how to budget for Lean manufacturing. While it’s not the same as attending the conference, we hope you find them full of information. We’ve embeded the videos in this post so you can watch them at your leisure. Let us know what you think in the...

Due to higher-than-average machine related injuries, OSHA has placed the printing industry on its list of high hazard industries for amputations. As a result OSHA has been very aggressive under its National Emphasis Program on the prevention of amputations through inspections of and enforcement on the printing industry. Safety in the workplace needs to be a top priority in print shops—especially when there’s the risk of serious injury and hefty penalties. We know accidents do happen and to help keep safety at the forefront of people’s minds we’ve developed a series of safety posters. This set of posters communicates the importance of equipment safety practices as they relate to basic lockout/tagout procedures, machine guarding, and proper use of safety controls. These posters stand out with their bright colors and pictures to remind employees to practice safe techniques. There’s even a QR code on the poster that, when scanned, provides the contact information for our manager of environmental health and safety affairs, Rick Hartwig. The set of posters is available as a free high-resolution PDF download for members ($15 for non-members) to print and display around equipment, hang in the pressroom, break room, or common area.  For more information about the safety posters or any of the products or services offered by Printing Industries of America’s Environmental, Health, and Safety department visit www.printing.org/compliance or call 800-910-4283, ext....